Consultation Response from South East Essex Friends of the Earth

Representation ID: 12485

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – 6 Timetable – Your Views

Representation: Given the two extensions to the second-phase consultation deadline, it is clear that the timetable for step 3 onwards must be pushed back and Nigel Holdcroft tells me that the Pre-submission consultation will not happen before September. One expects the statutory consultation to request formal proofs of evidence from people rather than the entirely unsatisfactory method used in the current phase – making people cram their responses into 100 words. It is also vital that contributions to the current consultation are used to shape the submission document in exactly the way the first phase consultation failed to shape the second.

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Representation ID: 12482

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – 5. Implementation, Delivery and Monitoring

Representation: It is clear to anyone with even an ounce of common sense that the policies and proposals in the plan are *not* realistic or deliverable. The numbers for job creation seem to have been plucked from thin air and bear no relation to the experience at other airport sites. The target number of passengers also appears to have been selected at random with no regard for the dire effect it would have on the surrounding area. It seems very unlikely, given the recession we are entering, that these numbers are even achievable, particularly given the current decline in aviation passengers.

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Representation ID: 12246

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy ENV6 – Green Buffer East of Railway

Summary:

To suggest that maintaining a small strip of grass between the airport and the houses on Southend Road will do anything whatsoever to protect the amenities of the residential properties is to insult the intelligence of the occupants of those properties. Even the suggestion that the airport will expand has caused house prices in the Rochford area to fall by a substantial amount (we have been told of figures of between £25,000 and £30,000). If the expansion were to proceed, these houses would become unsellable.

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Representation ID: 12229

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy ENV5 – Green Corridor to Business Park

Summary:

This policy is simply a joke. Doing a bit of landscaping at the roadside does not qualify in any way as an environmental policy. As has previously been discussed, the Saxon Business Park should not be developed.

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Representation ID: 12214

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy ENV4 – Country Park; Access and Facilities

Summary:

The Saxon Business Park should not be developed – existing industrial and commercial facilities should instead be improved and fully utilised. Therefore, there will be no need to make any changes to the existing junctions.

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Representation ID: 12212

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy ENV3 – New Public Open Space – South

Summary:

This area should retain its existing function.

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Representation ID: 12210

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy ENV2 – New Public Open Space – North

Summary:

Who, in their right mind, will want to use public open space that is immediately adjacent to what the joint councils hope will be a busy airport? This area should remain as farmland.

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Representation ID: 12200

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy ENV1 – Revised green belt boundary

Summary:

It is entirely unacceptable to reduce the green belt area to build unnecessary additional office space, industrial units, etc. There is a large amount of land in Southend that has previously been developed and is now either derelict or vacant. All of this land must be fully utilised before the use of any greenbelt land is even considered.

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Representation ID: 12177

SUPPORT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T9 – SERT

Summary:

The SERT is to be welcomed, but the JAAP can hardly take the credit for this. It should also be noted that there can be no such thing as "sustainable new development". By definition, sustainability is about living within one’s means. Constant expansion, as suggested by the "new development" part, is therefore entirely incompatible with this.

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Representation ID: 12164

SUPPORT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T8 – Walking and cycling

Summary:

Policy T8 is to be welcomed on the condition that cycling facilities do not take the approach at junctions that is seen at the Fossetts Way/Sutton Road junction, i.e. that cyclists have to give way to all other road traffic. Motorists need to get used to the idea that cyclists’ and pedestrians’ journeys have equal priority to their own.

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Representation ID: 12144

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T7 – Public Transport

Summary:

The SERT is an entirely separate project. As part of the JAAP scheme, multiple bus services (not just one as is suggested by the policy) should be provided in addition to SERT. It should also be noted that as this is *public* transport, it should be in public ownership. We have seen to our cost what happens when Southend’s bus services are in private ownership – they are public services and should not be expected to turn a profit for the operator on every route.

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Representation ID: 12137

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T6 – Green travel plans

Summary:

In principle, green travel plans should obviously be supported. However in this case, this is nothing more than greenwash. As has been pointed out by other respondents, it won’t make the slightest difference that people are walking to the airport (and is that really a likely scenario anyway?) when planes are taking off and landing every few minutes. Just as there is no such thing as a quiet plane, there is no such thing as an environmentally friendly one and to pretend otherwise is ludicrous.

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Representation ID: 12134

SUPPORT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T5 – Park and ride

Summary:

Southend has been crying out for a Park and Ride facility for years. This would be very welcome. However, were the runway extension to proceed, the location allocated is unsuitable as it breaches Policy LS5. Indeed, a large proportion of the facility lies within the existing Public Safety Zone. The solution is obvious: close the runway.

More details about Rep ID: 12134

Representation ID: 12129

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T3 – Upgrade to Cherry Orchard Way

Summary:

As discussed in our objection to policy T2, road widening is not a solution.

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Representation ID: 12127

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T2 – Safeguarded Route

Summary:

It has long been established that more roads result in more cars using them and therefore more congestion. This is why this policy should not be adopted and attention should instead be focused on policies T5-T9 coupled with other traffic reduction methods, such as congestion charging on the A127 and A13 at peak hours with the alternative of a free park and ride scheme at the point of charging paid for by the congestion charge.

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Representation ID: 12124

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy T1 – Link Road from Eastwoodbury Lane to Nestuda Way

Summary:

Conversely, with no runway extension, a new link road would not be necessary. Therefore, were the runway extension to go ahead, all costs for this link road must be met by the airport operator.

More details about Rep ID: 12124

Representation ID: 12123

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy ADZ1 – Existing Terminal Area

Summary:

It is completely inappropriate for Southend Airport to expand to 2mppa and therefore, this policy is simply wrong.

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Representation ID: 11570

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy MRO3 – Southern MRO Zone

Summary:

I object on the grounds that this policy provides further support for planning applications that have not been submitted. However, this is an appropriate place for MRO activity, provided that the close proximity of residential properties is taken into consideration and consequently, noise from these operations is minimised and strictly controlled.

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Representation ID: 11563

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy MRO2 – Northern MRO Extension

Summary:

Further pre-judgement of planning applications in this policy. The MRO should not expand into this green open space.

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Representation ID: 11558

COMMENT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy MRO1 – Northern MRO

Summary:

The continued operation of the MRO would be acceptable provided that the focus is on activities that do not involve the testing of engines, which is very noisy and disruptive to local residents – indeed, I have heard engine tests from the southern part of Priory Crescent when walking my dog and the noise has been sufficient to worry him to the extent that I dare not let him off the lead for fear that he would run away. Such activities should not take place in densely populated areas such as Southend.

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Representation ID: 11557

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy TF1 – Expansion of New Terminal

Summary:

Another case of the councils unacceptably declaring their position on an unsubmitted planning permission. My objections to Policy LS7 also apply here. Nigel Holdcroft has acknowledged that were there not currently an airport at this location, SBC would not support the development of one as it would be inappropriate. They should therefore not support the expansion of the existing airport as it is equally inappropriate.

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Representation ID: 11551

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy LS7 – Operation of New Runway

Summary:

Planning permission should not be granted, but conditions should be imposed regardless. However, the conditions specified are wholly inadequate. The night restriction should apply to *all* flights, not just scheduled passenger flights. A noise quota is not satisfactory in itself – a limit on the actual number of flights should also be enforced. Any breaches of conditions should result in a meaningful penalty being imposed on the airport operator. Monetary fines are not sufficient, as they would not benefit residents. A suspension of all flights for a 24-hour period following each breach of conditions would be more appropriate.

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Representation ID: 11544

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy LS6 – Runway Extension

Summary:

If the runway extension goes ahead, the airport operator must bear the full cost of the road diversion. Without the runway extension, the diversion would not be necessary. If individual councillors are not allowed to declare their positions in advance, it is outrageous that the joint councils can declare unconditional support for a planning permission that hasn’t even been submitted.

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Representation ID: 11537

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy LS5 – Public Safety Zones

Summary:

Firstly, the south-west zone shown on the Proposals Map is the current one. Without showing where it would move to were the runway extension to proceed and how much bigger it would be as a result of the increase in flights, it is not possible to plan appropriately. The Park & Ride scheme and the Nestuda Way Industrial Estate would both increase the number of people within the zone. I should note that the wording "*when* the runway is extended" supports the assertion made by many people that it is indeed a foregone conclusion that the runway will be extended.

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Representation ID: 11534

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy LS4 – Surface Access Strategy

Summary:

I fail to see why it is the airport operator’s job to prepare a Surface Access Strategy. There are limited options for access to the airport via road and rail and it should be for the Borough and District Councils to determine what routes are acceptable and to impose limits on the hours that HGVs can enter and leave the site, and load and unload, as they already do for retail outlets.

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Representation ID: 11528

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy LS3 – Noise Statement

Summary:

It should not be left to the airport to monitor and evaluate their own noise as they will naturally present all findings as positively as possible for themselves. In the interests of transparency and public confidence, all noise and pollution monitoring should be conducted by an independent and unbiased third party.

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Representation ID: 11526

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy LS2 – Development at London Southend Airport

Summary:

This policy is entirely at odds with the Climate Change Act and planning policy on sustainability and environmental protection. The "agreed [noise] baseline level" is entirely meaningless at this stage, as no such level has been set. The idea that getting people to catch the train or cycle to the airport is going to make any difference is laughable. In a ten minute period, a plane can cause more climatic damage than a car would do driving round the circumference of the planet (http://eans.net). The only *sustainable* course of action is to close the airport.

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Representation ID: 11510

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy LS1 – General Policy

Summary:

Who is it recognised by that the airport "can provide a key boost to the economy…"? Where is the evidence to back this assertion up? You only have to look at the claims made at other airports and then compare those with what actually happened to realise that the claims are wild exaggerations. Airports in this country take money out of the economy because the vast majority are flying away from the UK on holiday. Southend is not now and never will be an international holiday destination.

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Representation ID: 11233

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy E8 – Nestuda Way Business Park

Summary:

The south-west Public Safety Zone shown on the Proposals Map is the current one. Were the runway to be extended, the Public Safety Zone (PSZ) would move further south west. Additionally, as the outer PSZ area is defined as the area in which there is a 1 in 100,000 chance of being hit by an aircraft over the course of a year, a significant increase in flights would expand this area. The Nestuda Way Business Park site is already very close to the boundary of the current PSZ – it would certainly fall inside the new one, breaching planning guidance.

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Representation ID: 11227

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy E4 – Phasing of Saxon Business Park

Summary:

As described above in my response to Policy E3, it is wrong to use this agricultural land when there are plenty of suitable brown field sites that remain unused, such as the facility on the corner of Manchester Drive and Eastwood Boulevard.

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Representation ID: 11226

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy E3 – Saxon Business Park

Summary:

It is wrong to build on this agricultural land when there are so many existing industrial areas (e.g. Prittlebrook Industrial Estate) and office blocks (e.g. Victoria Avenue) that are currently vacant. As world oil supplies diminish, it will become increasingly important that the UK is able to grow its own food and not rely on imports.

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Representation ID: 6199

COMMENT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy E2 – Aviation way Industrial Estate

Summary:

It seems unlikely that businesses will want to move into this area given the additional financial contribution required of them. However, if it is expected that 750 jobs will be created on this site, that is to be welcomed. As previously discussed, the job creation targets should be enforced by being included in the Section 106 agreement.

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Representation ID: 6198

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Policy E1 – General Development Considerations

Summary:

As previously noted, the job creation potential of the JAAP is a wild exaggeration. See Brendon Sewill’s “Airport jobs: false hopes, cruel hoax” at http://www.aef.org.uk/uploads/Airport_jobs___false_hopes_cruel_hoax.pdf
I have also written a report, specifically addressing the employment potential of the JAAP area, and this is available at http://saen.org.uk/reports/Employment_Report.pdf

More details about Rep ID: 6198

Representation ID: 6196

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Issue 5

Summary:

Areas i, ii(a), ii(b), ii(c) and ii(d) should not change use as previously discussed.
Likewise, Area v’s amenity value has been underestimated due to the presence of agricultural land, which will gain a great deal of value during the coming years.
While a Park and Ride facility is to be welcomed, its location in Area xi is not as it falls within the Public Safety Zone.
While it is recognised that planning permission has already been granted, area vii should not be used as a station due to the reasons previously noted, particularly the close proximity of Rochford station.

More details about Rep ID: 6196

Representation ID: 6192

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Issue 4

Summary:

If issues i. and ii. are dealt with correctly, they will remove the need for any road “improvements” or new routes. As previously noted, the double-whammy of Peak Oil and Climate Change are conspicuous by their absence from all of the JAAP documents. In order to meet Climate Change Act targets, both local authorities will be required to achieve a 40% reduction in CO2 emissions by 2020 and this will only be possible with a significant effort to reduce private car use. See http://www.foe.co.uk/resource/reports/tyndall_climatereport_ccc2008.pdf

More details about Rep ID: 6192

Representation ID: 6189

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Issue 3

Summary:

Aviation growth is unsustainable and a phased aviation reduction strategy is the only way to successfully manage the environmental impacts of the airport.
It is necessary to limit industrial estate or “business park” growth to the existing boundaries. Loss of agricultural land is unacceptable given the need for the UK to become self-sufficient in food during the next 15-20 years as a consequence of Peak Oil.
If biofuel technologies are pursued, farmland will be put at even more of a premium. Thus, a wise planning authority will reuse all existing “brownfield” sites before permitting any agricultural or greenbelt land to be used.

More details about Rep ID: 6189

Representation ID: 6187

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Issue 2

Summary:

While modest employment growth at the site would be welcome, the growth proposed is both irresponsible and unachievable. Again, see Brendon Sewill’s report “Airport jobs: false hopes, cruel hoax”. The destruction of a number of areas of greenbelt in order to expand the industrial site is completely unnecessary given the abundance of available sites in Southend, such as the recently-demolished Prittlebrook Industrial Estate and vacant buildings elsewhere in the borough.
However, if the airport and councils believe job creation potential to be this great, the Section 106 agreement should require 5000 jobs to be created at the site within five years.

More details about Rep ID: 6187

Representation ID: 6186

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Issue 1

Summary:

The airport railway station is a classic example of “greenwash” – suggesting that using the train to get to and from the airport will make it more environmentally friendly is pure nonsense. The marginal savings made by using rail instead of a car are dwarfed by the aircraft emissions. An extra stop will also be a disbenefit to rail users not wishing to use the airport as it will increase journey times. Rochford station is sufficiently close that a minibus service between the station and the airport would be a better solution.

More details about Rep ID: 6186

Representation ID: 6184

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – Issue 1

Summary:

As previously described, airport expansion is fundamentally incompatible with the concept of sustainable development. Instead, a global policy of phased aviation reduction is required in order to cut greenhouse gases and preserve remaining oil supplies for more important uses: manufacturing, agriculture and surface transport.

More details about Rep ID: 6184

Representation ID: 6183

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – 2 Assets, Opportunities and Constraints

Summary:

Neil Punnett should realise that aviation accounts for 13% of current UK carbon emissions. With the Government seeking to double aviation by 2030, aviation alone would exceed the carbon limits in the Climate Change Act.
Rick Jackson should note that the “Saxon Business Park” is entirely separate from the proposed airport expansion and will provide non-aviation based employment. See “Airport jobs: false hopes, cruel hoax” by Brendon Sewill for a more realistic assessment of the employment opportunities an airport can provide.

More details about Rep ID: 6183

Representation ID: 6181

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – 2 Assets, Opportunities and Constraints

Summary:

To describe the Saxon Business Park as “award winning” when it doesn’t yet exist and therefore cannot have won any awards is self-evidently dishonest. Likewise, there is no way to know at this stage that the airport “will be a successful regional passenger airport”.
No mention of Peak Oil is made either in the “Preferred Options” or the “Sustainability Appraisal” documents. By 2021, it is likely that oil will be considerably more expensive than it was in 2008, making aviation, which already has extremely tight margins, economically unviable. Note that globally, aviation currently has a profit margin of 1%.

More details about Rep ID: 6181

Representation ID: 6179

OBJECT South East Essex Friends of the Earth

London Southend Airport & Environs Joint Area Action Plan Preferred Options – 1 Introduction

Summary:

The “Report Summary of Responses to Consultation” for the first phase of consultation on the JAAP indicates that “Despite some support, the majority of respondents were opposed to Scenario 3.” It is therefore utterly ridiculous for RDC and SBC to describe phase 2 as the “Preferred Options” while pursuing the least popular Scenario.
Aviation expansion is inherently unsustainable due to limited resources (i.e. Peak Oil) and pollution emitted by aircraft (e.g. causing Climate Change). Any Sustainability Appraisal that supports the expansion of Southend Airport must therefore be wrong.

More details about Rep ID: 6179